Arm's length principle: adjust profits between associated enterprises to reflect independent enterprise conditions, permitting inclusion and taxation of unrealised profits. Article 10 establishes that where relatedness between enterprises causes commercial or financial conditions to differ from those between independent enterprises, any profits that would have accrued but for those conditions may be included in the profits of the affected enterprise and taxed accordingly, functioning as a transfer pricing adjustment under the DTAA.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Arm's length principle: adjust profits between associated enterprises to reflect independent enterprise conditions, permitting inclusion and taxation of unrealised profits.
Article 10 establishes that where relatedness between enterprises causes commercial or financial conditions to differ from those between independent enterprises, any profits that would have accrued but for those conditions may be included in the profits of the affected enterprise and taxed accordingly, functioning as a transfer pricing adjustment under the DTAA.
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